-26-
the Clay County property was worth $1,150,555 ($497 per acre) on
the date decedent transferred an undivided one-half interest in
it to petitioner.
Elmore stated that the Seminole property sold in 1979 and
the Putnam County property sold in 1980 to the Thompson
partnership were comparable to the Clay County property. For the
reasons stated above at paragraph II-B-4-a, we believe that
Elmore relied too greatly on these two sales to establish the
value of the Clay County property.
Elmore also used as comparable sales decedent's and
petitioner's 1986 sale of 329.26 acres of the Clay County
property for $911 per acre and the 1982 sale of 2,230 acres from
J.P. Hall & Sons, Inc., to Georgia-Pacific for $500 per acre (the
Hall property).
Elmore's report states that the Hall property was primarily
(about 90 percent) wetlands and that Georgia-Pacific bought the
property for its peat deposits, which had an estimated production
value of $1,500 per acre. Elmore did not consider whether the
Clay County property had peat deposits. The Clay County property
was 35 percent wetlands.
Respondent argues that petitioners' suggestion that Georgia-
Pacific paid more for the Hall property because it had peat
deposits erroneously assumes that Georgia-Pacific would have no
production costs. We disagree. Elmore's report states that
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